The reason I originally posted the above case is because it points to the importance of asking for a reserved decision on costs at every step of a case- at every conference.

If the other party has a lawyer they need to be explaining to their client how and why costs can be ordered and how costs can now be enforced.

Even if the other side is posturing as destitute (can't be bothered to get a job), if they act unreasonably and the court sees through the claims of destitution and costs are ordered, the costs can in the end be recovered through an offset against child support arrears. This seems like it could be wielded as a lever toward reasonableness.

In conjunction with costs orders being enforceable by FRO, this could be helpful.